Contractor HSE Handbook

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CONTRACTOR

HEALTH / SAFETY / ENVIRONMENTAL (HSE)

HANDBOOK

Shell Exploration & Production Company

(SEPCo)

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Respect and Safeguard People

• Pursue a goal of no harm to people, whether employees, contractors or others affected by our activities

• Provide good and competitive terms and conditions of service

• Value and promote diversity.

• Promote high standards of health and safety in our industry Use Resources Efficiently

• Using all resources, land, energy, materials, efficiently to provide products & services

• Use less resources and generate less waste

• Promoting web based technologies and e-business

Engage and Work with Stakeholders

• Actively seek out, listen and respond to those with an interest in our activities

• Proactively provide information about our activities

• Publicly report our performance

• Build trusting and mutually beneficial partnerships and relationships Maximize Profitability

• Effectively manage costs to deliver superior and sustained financial performance

• Work in beneficial partnerships with contractors and sub-contractors, alliances and joint industry projects to share services and costs

• Cooperate and use leverage in the market place for contracting and procurement Minimize Impact on the Environment

• Set targets to progressively reduce emissions and discharges

• Be aware of SEPCo’s environmental efforts to conserve bio-diversity Maximize Benefits to the Community

• Consider hiring employees from the work location’s local community

• Procure local products and services where possible and develop partnerships and alliances with local suppliers and contractors

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Contractor HSE Handbook Index

A

Air hoist...22, 23, 59 Alcohol...13, 14, 16, 26

All Terrain Vehicles (ATV’s)...19

Asbestos...26, 32 Atmosphere...13, 39, 42, 51, 52 B Battery Charging...61 Boats...27, 29 BOP...54 C Carbon Dioxide (CO2)...62

Casing Crew...58

Cementing...59

Cheater Bars/Pipes...52

Cold Stress...33

Compressed air...41, 52 Confined Space Entry...34, 38, 39, 50 Contact lenses...19, 26 Cranes...44, 45, 47 Cylinders, oxygen and acetylene...41

D Drilling operations...22, 27, 38, 39, 40, 54, 60 Drills...13, 14, 17, 29, 54 Drugs...16, 26 E e-aspects...30 Electrical Safety...42, 43 Electrical storms...54, 60 Emergency drill...17, 29 Environmental...12, 13, 14, 29, 31 Environmental Compliance Manual (ECM)...31

Equipment Spacing...43, 61 Excavation...34, 49, 55 Explosives...54, 59, 60 Eye Protection...19, 20, 51 F Fall protection...21, 22, 23, 24, 25 Fire drill...17 Fire extinguisher...17 Fire Prevention...17 Food Control...33 Foot protection...20 Forklift...53, 56 Full body harness...21, 22, 23, 25 G Gin pole...44, 45, 47, 56, 62 Grounding...53, 55 Guard rail...21, 24, 25, 26 H Hair...26, 44 Hand Protection...20 Hand tool...24, 53 Harassment...15

Hazard Communication (HAZCOM)...32

Hazardous atmosphere...39, 62 Head Protection...19 Hearing protection...20, 27, 51 Heat stress...33 Helicopter...16, 26, 27, 46 Hot tapping...41 Hot Work...34, 40, 41, 42 Housekeeping...16 HSE meeting...13, 15, 18 HSE orientation...12, 27 HSE Responsibilities...12 Hydraulic winch...22, 23 Hydrogen sulfide (H2S)...26, 39, 62 I Incident investigation...13, 14 Incident reporting...14 ISO 14001...29 J Jewelry...19, 44 Job hazard analysis (JHA)...35

Job safety analysis (JSA)...18, 35 L Labeling...31, 32 Ladders...24 Lead...33, 42, 50, 51 Lifting of Personnel...22 Lockout / Tagout...34, 37, 43, 44 Loose clothing...44 M Man-made mineral fibers (MMMF)...26, 33 Management of Change (MOC)...35

Material safety data sheets (MSDS)18, 19, 20, 32 Medical Response Plan...31

Mentor...15

Mineral wool...33

Mismatched Hammer Unions...55

N Naturally occurring radioactive material (NORM)...32

Nitrogen (N2)...62

O Occupational health...31

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Offshore...17, 27, 28, 29, 31, 40, 45, 46, 47 Operating equipment...44 P

Painting...50, 51 Perforating...54, 59, 60 Permissible exposure limit (PEL)...33, 62, 63 Permit-to-work (PTW)...34, 35 Personal flotation device (PFD)...26, 27, 28, 29 Personal protective equipment (PPE)...12, 13, 18,

19, 29, 31, 32, 34, 43

Pickup/laydown machine...54, 58, 59 Pipe Racks...57 Power lines...43, 55 Power tool...16, 53 Pre-Job HSE meeting...18 Prescription...31 Professional Conduct...15 Protective clothing...20, 33 R Respiratory protection...26, 51, 52, 62 Rig Move...23, 38 Rigging...23, 44, 45, 46 S

Safe Welding Area (SWA)...40, 41 Sandblasting...33, 50 Scaffolding...50 Secondary Fall Protection...22 Security...16, 17 Seismic operations...19, 60 Short Service Employee (SSE)...12, 13, 14 Signs...14, 26, 51, 52, 59, 62, 63 Sling...45, 46 Slips...57 Smoking...14, 16, 17, 27 Solvents...16, 51 Spill (SPCC) Plan...30 Static electricity...43, 60 Station bill...17, 29 Stop work or operations...11, 13, 14, 44, 45, 46 Subcontractor...11, 15 Swimming...28 T Tag lines...45, 46 Tank Roof...25 Tongs...57, 58 Toxic vapors...51 Training 12, 13, 18, 26, 28, 29, 32, 33, 36, 45, 53, 62 Trenching...34, 49, 50, 55 Tubular Handling...56 Tubular Loading/Unloading...56 V Vehicles...19, 20, 26, 27, 61 Ventilation...39, 42, 51, 52 Visitors...20, 31 W Waste Management...30 Weapons...14, 16 Weather...16, 18 Welder...20, 41, 42 Well servicing operations...22, 53 Wire rope...23, 45, 46 Work Permit...18, 25, 34, 35, 39, 40, 41, 43, 50

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INTRODUCTION

SEPCo is committed to a safe workplace, the protection of the environment and health (HSE) for all SEPCo and contractor employees. However, your help will be needed to accomplish this objective. SEPCo believes that HSE is a team effort and the responsibility of all - it will take everyone working together to reduce and eliminate HSE incidents.

The use of the word "contractor" in the context of this handbook means all contractor employees - both primary contractors and their subcontractors. The HSE compliance of subcontractors is the responsibility of the primary contractor. Consequently, the primary contractor shall have provisions in place to monitor, document and effectively manage subcontractor HSE programs and performance.

This Contractor Health, Safety and Environmental (HSE) Handbook is a guide to your responsibilities on the job while on SEPCo premises. This handbook outlines the minimum expectations you and your company shall comply with while working on SEPCo premises. Of course, good judgment and clear thinking are required to supplement any rules. HSE shall be a core value in all work performed for SEPCo. If you are in doubt at any time whether the health, safety, and/or environmental aspect of the operation at hand are being properly managed, stop the work and consult your supervisor or the SEPCo representative. It is your duty to report conditions that could lead to an HSE incident and to stop the operation immediately until conditions are fixed or safeguarded. In addition, you are required to report all HSE incidents, including accidents and injuries, as soon as possible to your supervisor or the SEPCo representative.

Your company was hired by SEPCo because of its HSE and on-site job performance. You shall comply with all policies, rules and procedures set forth

by your company, as well as any site-specific SEPCo policies. Your company's contract with SEPCo may be canceled or an individual may be requested to leave SEPCo premises and not return if the guidelines of this handbook are not followed. We welcome your feedback to improve this HSE process and the resulting HSE performance on SEPCo locations.

How to Use This Handbook

All SEPCo and contractor employees (including subcontractors) must understand the contents of this HSE handbook. Contractors shall maintain documentation in the form of an SEPCo-issued orientation card on SEPCo locations to confirm that their employees (including subcontractors) have attended an orientation session

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covering this HSE handbook. If an employee start date is in between the scheduled SEPCo HSE orientations, they may work under temporary approval by receiving an on-site orientation from the SEPCo representative. However, the employee must then attend the next offered orientation session in order to continue working for SEPCo.

1.0 HSE RESPONSIBILITIES

1.1 Contractor

• Adhere to SEPCo's Short Service Employee (SSE) process - Contractors shall adhere to SEPCo's SSE process as described in Section 1.4 of this handbook and effectively manage their SSE's through training, mentoring, etc.

• Perform all work in a manner to prevent HSE incidents - Contractor employees shall follow all SEPCo HSE policies and procedures and applicable Federal, State and local HSE rules, regulations and ordinances while working on SEPCo property.

• Ensure training and proper tools/equipment - Contractor shall ensure their employees are trained in appropriate HSE subjects and specific job procedures. Documentation of training is required. Contractor shall provide the proper tools and equipment for their employees to perform a job in a manner to prevent HSE incidents.

Contractor shall ensure that their employees have the appropriate personal protective equipment (PPE) and have been trained on how to use the PPE properly.

• Notify SEPCo immediately of any health, safety or environmental (HSE) incidents, even if no injury occurs. Provide SEPCo with a written report within 24 hours - Contractors shall fully investigate all HSE incidents beyond simple cause by examining organization, communication, etc. issues. Contractor shall provide SEPCo with a written report which includes the root cause of the incident and a corrective action plan (steps taken to prevent another incident). In addition, a doctor's release for injuries requiring medical treatment by a physician shall be provided before personnel return to work.

• Proactive HSE efforts - SEPCo and contractor employees are expected to have programs in place that proactively ensure improvements to health, safety and environmental (HSE) performance. This includes, but is not limited to, observing the behaviors of

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employees to positively reinforce behaviors that prevent HSE incidents and correct behaviors that do not. HSE performance shall be monitored and documented. Contractor management should be accountable for HSE performance.

• Contractor shall hold a pre-job or pre-task HSE meeting on-site in which the specific hazards pertaining to the job are discussed prior to beginning all work.

• Contractor shall have their own written drug, alcohol and firearms policy in effect.

1.2 SEPCo Employees

• Communicate SEPCo HSE Policies and Procedures - Ensure that the appropriate SEPCo HSE policies and procedures are communicated to all working on SEPCo locations, including contractor employees. Enforce SEPCo’s Short Service Employee (SSE) process and also the requirement that all contractor employees attend a SEPCo orientation session covering this Contractor HSE handbook.

• Wear required personal protective equipment (PPE) and receive training on how to use the PPE properly.

• Conduct routine audits, inspections and drills, as well as formal audits.

• Promptly fix or safeguard conditions and correct behaviors deemed to be a risk to HSE.

• Create an atmosphere in which HSE issues are reported,

discussed and resolved and one in which everyone feels it is their duty to stop an operation immediately if conditions or behaviors present a risk to HSE.

• Ensure HSE management systems are in place that address the responsibilities, practices, procedures, processes and resources needed in order to fully integrate health, safety and environmental issues into work place culture.

• Participate in HSE incident investigations including root cause analysis and development of a corrective action plan.

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• SEPCo requires that all health, safety or environmental (HSE) incidents be reported immediately even if no obvious or

noticeable HSE impact resulted (i.e. Near Miss).

• Immediately stop any work in which HSE is not being properly managed.

• Actively participate in HSE programs including meetings, drills, audits, incident reporting, and incident investigation, etc.

• Adhere to SEPCo smoking, weapons, drug & alcohol, and driving policies.

• Read all signs as you enter location and follow instructions.

• Be fit for duty including having proper rest, being in the proper mental state of mind, etc.

1.4 Short Service Employee Process (SSE)

Contractor personnel with less than six (6) months in the same job type or with his/her present employer shall be considered a Short Service

Employee (SSE).

• It is the contractor supervisor's responsibility to notify the SEPCo representative of the intent to use a SSE prior to the crew coming to the job site.

SEPCo's SSE Crew Percentage Requirements:

Crews with four (4) persons or less: A one-man "crew" cannot be a SSE. Two- to four-man crews can only have one (1) SSE per crew. Crews with five (5) persons or more: If the crew complement exceeds 20% SSE employees, the SEPCo representative shall approve the crew prior to beginning work, notify ATL, and obtain superintendent concurrence. Crew complements that exceed 30% SSE employees shall only be permitted with written variance approval by the ATL or Operations Manager, with Asset Manager notification.

• The Contractor SSE form shall be provided by the contractor prior to the crew coming to location. Appropriate SSE forms are located in the Contractor HSE Management Process (CSMP) manual.

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• All SSE personnel shall be assigned a mentor (typically an experienced employee) to assist the employee during his/her "SSE" period. The mentor shall provide close supervision to the SSE personnel and not allow him/her to perform any task in which they have not been properly trained. In addition, it is SEPCo's expectation that the SSE employee not only attend the contractor's initial

orientation prior to beginning work on a SEPCo location, but also the SEPCo orientation session covering this Contractor HSE handbook.

• SSE personnel shall be distinguished by either a sticker placed on their hard hat that must include the letters "SSE" and be of contrasting color to the hard hat or by assigning them a different color hard hat that would distinguish them from experienced employees.

• To remove an employee from the SSE status, the employee shall demonstrate behavior conducive to HSE (i.e. no injuries, participated in HSE programs, attended HSE meetings, etc.) for six (6) months and have a general awareness and working knowledge of the contractor's and SEPCo's HSE policies. The contractor may reduce the six (6) month requirement with approval of the SEPCo representative based on the employee's HSE performance. Documentation should be

maintained for a period of one (1) year after a contractor employee has been removed from SSE status.

• Contract employees who do not qualify for release from SSE status after six (6) months may work on SEPCo property only with the approval of the SEPCo superintendent.

• Contractors will manage their subcontractors in alignment with this SSE policy.

2.0 SEPCo WORKPLACE PRINCIPLES AND POLICIES

2.1 Professional Conduct

While on SEPCo premises, each employee shall conduct themselves in a professional manner - horseplay, practical jokes, or any type of

harassment is not allowed. This includes sexual harassment, which will not be tolerated on SEPCo premises. Male and female employees are entitled to a workplace free from sexual harassment. Sexual harassment includes unwelcome sexual advances, requests for sexual favors, threats, actual bodily contact, and other verbal or physical conduct of a sexual nature which interferes with an individual's work performance or creates an intimidating, hostile or offensive working environment.

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2.2 Drugs, Alcohol and Weapons

The use, possession, transportation, promotion or sale of illegal drugs, controlled substances, drug paraphernalia, alcohol, firearms or weapons while on SEPCo premises, whether owned or leased, is absolutely prohibited. Use of prescription or over-the-counter (OTC) medications that may impair your ability to work safely shall be discussed with your supervisor before beginning work.

SEPCo reserves the right to search the person, vehicle and other property of individuals while on SEPCo's premises. These searches may be conducted without prior announcement and at such times and locations as deemed appropriate. Contractor’s personnel who refuse to cooperate with a search will not be allowed on SEPCo’s premises.

2.3 Housekeeping

All walking areas, work areas, handrails, equipment, tools, fire-fighting and life-saving equipment, etc. shall be kept clean and free of obstructions. Good housekeeping is essential so work may proceed in a safe and orderly manner. Tools should be placed appropriately as to not cause a hazard to the job at hand while in use and promptly put away after use. Hand and power tools shall be kept in good condition with guards in place without modification defective tools shall be repaired by qualified repairpersons or replaced. When cleaning grease from equipment and tools, detergents and water or steam are preferable over solvents from an HSE standpoint. Only SEPCo-approved solvents shall be used and gasoline is not allowed for cleaning.

2.4 Smoking

Smoking, matches or lighters are only allowed in designated smoking areas. In addition, they are not allowed in or around helicopter landing areas or while in flight unless the pilot has given permission. Only safety matches (no "strike-anywhere" matches) or lighters with the sparking mechanism enclosed (no disposable lighters) are permitted.

2.5 Adverse Weather Conditions

When adverse weather conditions present a potential risk to HSE, SEPCo expects good judgment to be used and action taken, up to and including shutting down the job, to protect HSE.

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Contractors shall be responsible for their own equipment and held accountable for controlling the actions of their employees while on SEPCo premises. SEPCo is not responsible for lost or stolen articles.

Cameras are not permitted on location without prior approval of the SEPCo representative.

Contractors shall not bring unauthorized individuals (i.e. friends, relatives or observers) onto SEPCo premises. SEPCo and contractor employees shall observe landowner requirements for site security (i.e. close/lock doors and gates, etc.).

2.7 Fire Prevention

U.L. approved explosion proof equipment shall be used in all offshore locations and any other location where flammable mixtures may be present. When handling flammable materials, smoking, open flames, or electric arcs are prohibited. All combustion engines should be shut down before fueling except when the refueling location is sufficiently removed from the engine. Extreme caution should be followed in areas where flammable vapors are present or suspected.

Combustible materials such as rags, paper, and trash shall be disposed of in proper containers and the containers labeled. Flammable liquids such as gasoline, kerosene, fuel oil, etc. shall be transported and stored only in approved metal containers and the containers labeled.

Fire fighting equipment shall not be altered, tampered with or blocked. All employees are expected to be familiar with the location of the portable fire extinguishers and emergency response plan, including fire alarms, and participate in fire drills.

2.8 Emergency Response and Drills

SEPCo employees and contractors shall be familiar with emergency response plans for the SEPCo location, including facility and plant alarms, and shall participate in emergency drills.

Offshore Specific - Emergency evacuation drills shall be conducted monthly for each crew working offshore. Instructions are outlined in the “Station Bill” in each living quarters. It is your duty to read, review and understand the posted “Station Bill” and to participate in the drills.

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3.0 HSE MEETINGS

3.1 Scheduled HSE Meetings

Regularly scheduled (minimum monthly) HSE meetings shall be conducted by each contractor and attended by all personnel. Topics may include HSE issues; regulatory issues; HSE training; HSE trends that have been identified; etc. A record of these meetings shall be kept that includes date, location, names/signatures of attendees, and topics covered.

3.2 Pre-Job HSE Meetings

A pre-job or pre-task HSE meeting shall be conducted on-site prior to beginning all work in which the specific hazards pertaining to the job are discussed. Additional meetings may be required throughout the same day in the event a non-routine job is performed, in order to review a JSA or work permit prior to beginning a specific task, or in the event a change in job scope occurs. Everyone shall attend and participate in all HSE meetings unless specifically instructed otherwise. A record of these meetings shall be kept that includes date, location, names/signatures of attendees, and topics covered.

Suggested Topics for a Pre-Job HSE Meeting:

• Tasks - Discuss the task and job steps.

• PPE - Discuss what PPE is needed for the job.

• Responsibilities - Establish who has the overall responsibility for the job and ensure that each individual understands their assignment.

• Skills - If special job skills are needed for a task, ensure proper training has been provided. Discuss SSE's and how they will be managed.

• Emergency Evacuation - Discuss gather-up point, evacuation route, nearby hospitals, who are the first responders, etc.

• Environment - Discuss weather (heat, cold, wind, lightning, etc.) and location hazards such as snakes, insects, uneven walking surfaces, etc.

• Hazards - Discuss any location or job hazards not previously discussed in other portion of HSE meeting or during review of JSA or Work Permit.

• Equipment - Discuss any special tools that will be needed for a task and the HSE aspects of their usage including proper PPE.

• Materials - Discuss HSE aspects associated with materials including proper PPE and review MSDS if appropriate.

• Conflicting Activities - Discuss other activities or simultaneous operations (SIMOPS) that may affect the operation.

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4.0 PERSONAL PROTECTIVE EQUIPMENT (PPE)

4.1 General

All employees working on SEPCo premises shall wear appropriate personal protective equipment (PPE). It is the responsibility of each person to wear PPE as required by the specific task being performed, the potential hazards that person will be exposed to, and the specifics of the job site. PPE requirements as recommended on Material Safety Data Sheets (MSDS) for material being handled shall be strictly adhered to. In addition, all employees working on SEPCo premises shall wear a shirt and long pants at all times. Tank tops, sleeveless shirts, and short pants or cutoffs are not permitted. Loose or floppy clothing is prohibited around rotating or moving equipment. Rings, neck chains or loose jewelry shall be removed while engaging in manual labor.

4.2 Head Protection

An approved ANSI Z89.1 Class B (plastic) hard hat shall be worn by all employees working in SEPCo field operations at all times except while in vehicles, living quarters, offices and control rooms. While using All Terrain Vehicles (ATV’s), such as during seismic operations, an approved helmet shall be worn in place of a hard hat.

4.3 Eye Protection

Safety glasses with side shields shall be worn by all employees working in SEPCo field operations at all times except while in vehicles, living

quarters, offices and control rooms. All eye protection must comply with ANSI Z87.1. During night operations, only clear or amber colored safety glasses shall be worn. Contact lenses may be worn; however, safety glasses with side shields are required. OSHA does not allow contact lenses to be worn while using a respirator.

When performing work where safety glasses do not provide adequate protection, such as use of high-pressure washer, handling chemicals, etc. other appropriate eye protection such as goggles, etc. shall be worn. Hard hats with full-face shields will be required for all buffing and grinding operations.

Welding Specific - Welding hoods shall be used during all arc-welding operations. Goggles or other suitable eye protection with appropriate filter

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lenses shall be used during all gas welding, gas cutting or brazing operations. All filter lenses and plates used in welding hoods and goggles shall meet the test for transmission of radiant energy prescribed in ANSI Z87.1.

Welders’ helpers and entry attendants shall use proper eye protection. When not engaged in a welding or cutting activity, safety glasses with side shields will be worn by welders and welders’ helpers.

4.4 Foot Protection

Steel toe or a non-conductive (electrician's) safety toe shoes or boots with non-skid soles shall be worn by all employees working in SEPCo field operations at all times except while in vehicles, living quarters, offices and control rooms. All safety toe footwear must comply with ANSI Z41.1.

Visitors not performing work on SEPCo property may not be required to wear steel toe shoes in certain areas if escorted by a designated employee. Consult with the local SEPCo representative for

exceptions.

4.5 Hand Protection

Appropriate gloves shall be worn when the hands are exposed to hazards such as cuts, punctures or abrasions (cloth, leather or leather-palmed gloves); when handling chemicals or hazardous materials where

absorption is a concern (rubber gloves); and when performing electrical work (certified gloves for electrical work).

Welding Specific - Flameproof gauntlet gloves shall be used during all arc welding, gas welding or gas cutting operations except when engaged in light work such as test fitting pieces.

4.6 Hearing Protection

Hearing protection shall be worn in all high noise areas or wherever a high-noise warning sign is posted.

4.7 Protective Clothing

Special protective clothing shall be worn when handling chemicals or in other hazardous situations as specified by the Material Safety Data Sheet (MSDS). Clothing worn while working on live electrical equipment shall be 100% cotton, wool or a cotton-wool blend.

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During seismic field operations, all personnel shall wear high-visibility work vests, preferably fluorescent orange in color.

4.8 Fall Protection

Fall protection equipment shall be worn when working or climbing more than six (6) feet above an established working surface (ground, deck or water level); when specified on a warning sign; or when an immediate danger exists below the working surface regardless of height and no guard rails are present. All components of the fall protection system must comply with ANSI Z359.1

4.8.1 Working Above Six (6) Feet

Any employee working or climbing more than six (6) feet above an established working surface (ground, deck or water level) shall use one of the following means for primary fall protection:

• The preferred system for primary fall protection consists of: (a) a full body harness; (b) shock absorber; (c) clevis with cotter pin locking device or snap hooks with an inward moving, self-closing, and self-locking keeper (latch or gate) so that keeper remains closed and locked until unlocked and pressed open for connection or disconnection; and (d) nylon lanyard (steel or rope lanyards are not allowed) attached to a stationary support. The lanyard will be attached to a stationary support in a manner that will prevent a free fall of more than six (6) feet or even less than six (6) feet if an immediate danger exists below the working surface regardless of height.

• A retractable lifeline (inertia reel) attached to a full body harness may be used with appropriate SEPCo approval.

• A cable-grabbing device attached to a static line may be used with appropriate SEPCo approval.

• When ascending or descending a derrick ladder, and using the derrick climbing line run through a fall arresting device and connected to a counterweight, the derrick belt must be used in conjunction with the full body harness. The derrick belt should be worn over the full body harness and attached to the derrick climbing line.

• A double lanyard climbing method shall be used with appropriate SEPCo approval if none of the above-described primary fall protection devices are available.

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Fall protection devices such as full body harnesses, lanyards, static lines with cable-grabbing device, inertia reels, etc. shall be

inspected before each use and replaced if necessary. Fall protection equipment, which has been involved in a fall, shall be replaced.

Full body harnesses and lanyards shall be kept clean and never laid down in drilling mud, water, dirt, etc. All fall protection equipment shall be placed in a proper storage area when not in use. Only approved cleaning products for full body harnesses and lanyards shall be used in order to not diminish the rated capacity of the device.

4.8.3 Lifting of Personnel with Air Hoist or Hydraulic Winch Work procedures requiring personnel to be lifted on an air hoist or hydraulic winch line shall be avoided as much as possible by redesigning the work procedure, equipment, etc. However, there will be certain circumstances, especially in drilling and well

servicing operations, which will require personnel to ride an air hoist or hydraulic winch line. The following procedures shall be adhered to during personnel lifts on an air hoist or hydraulic winch line:

• Primary Fall Protection - The rider shall wear a full body harness designed for lifting personnel. The full body harness shall comply with ANSI Z359.1 and have certification that states that the harness meets or exceeds the load weight that may be imposed on it. The personnel lifting hook shall either be a clevis with a cotter pin locking device or a snap hook design with an inward moving, self-closing, and self-locking keeper (latch or gate) and will be attached to the front of the full body harness. Knots used in chains for lifting personnel are

prohibited.

• The air hoist and/or hydraulic winch shall be specifically designed and certified for personnel lifting. It shall have a self-centering control that, when released, returns to a positive locking/braking action in a center position. Freewheeling air hoists or hydraulic winches are prohibitedair or hydraulic power shall be necessary to operate the hoist in either direction. Use

of catheads or catlines for lifting personnel are prohibited. A

shut-off valve that is easily accessible by the operator shall be attached to the air hoist and/or hydraulic winch.

• Secondary Fall Protection - Secondary fall protection is required for personnel riding an air hoist or hydraulic winch in

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the derrick of a rig and/or in situations where it is necessary to unhook to change locations. Secondary fall protection shall be in the form of a static line with a cable-grabbing device attached or a sala block (inertia reel or retractable lifeline) and will be attached to the back of the full body harness.

• All components of the personnel lifting system including cables, air hoists or hydraulic winches, connections, full body harnesses and lifting hooks shall be inspected before each use and replaced if necessary.

• The lifting cable shall utilize factory-installed wire rope clamps and thimbles.

• All of the referenced hoisting equipment and devices shall have a minimum workload of 4,000 pounds.

• Lifting personnel on an air hoist or hydraulic winch line while the line is carrying another load is prohibited.

• Rotating equipment shall not be engaged while lifting personnel on an air hoist or hydraulic winch line.

• There shall be visual contact between the operator of the air hoist and/or hydraulic winch and the person being lifted at all times.

• The operator of the air hoist and/or hydraulic winch shall remain at the controls at all times while lifting, suspending or lowering personnel.

• An easily accessible emergency power isolation control shall be attached to the air hoist and/or hydraulic winch.

4.8.4 Fall Protection During Onshore Rig Moves

Some specific areas where fall protection must be worn during onshore rig moves are:

• When the permanent guardrails on the rig floor are removed during rig down and when rigging up, temporary guardrails such as properly strung cable shall be installed (cable should be installed prior to removing the permanent guardrails). If it is not possible to install temporary guardrails, a full body harness with a shock-absorbing lanyard attached to a stationary support as described in 4.8.1 above shall be used.

• When dismantling the derrick and substructure, fall

protection will be continually used. This may be accomplished by:

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◊ Use of man-lifts.

◊ Use of a cable-grabbing device attached to a static line that is properly secured inside the derrick mast.

◊ Use of inertia reel, double lanyard climbing method, or properly secured portable ladder to safely access the

derrick.

◊ Providing a retractable stand to connect and disconnect derrick-raising lines on A-frame type rigs. 4.8.5 Guard / Hand Rails & Barricading

Reference Fall Protection Standard, HSE 0044

Guard / Hand rails and or barricading shall be provided for:

• A walkway or wall opening from which there is a drop of more than four (4) feet.

• An open-sided working surface from which there is a drop of more than six (6) feet. Vee-doors on rig floors is one such example and should have a guard rail, safety chain or safety cable across the opening when pipe is not being picked-up or laid down.

• Walkways with missing, broken or loose guardrails shall be taken out of service until repaired.

4.8.6 Ladders

A ladder should always be used to reach objects or areas not readily accessible to the employee’s reach.

• All ladders shall be inspected before use. Any damaged or unsafe ladders shall be tagged and taken out of service.

Stationary ladders with missing, broken or loose steps shall be taken out of service until repaired.

• Both hands shall be kept free for climbing, descending and performing work on a ladder. No carrying of hand tools, grease guns, etc. while climbing on ladder. Articles, which are too large to be carried in a pocket or on a belt, shall be lifted and lowered by a hand line. Employee should not rush and should only take one step at a time.

• Only one person at a time shall be on the ladder.

• Portable ladders shall have anti-slip safety feet and be secured at the top before work begins in order to prevent the ladder from shifting. A second employee should hold the ladder

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until the climber can secure it at the top. In addition, portable ladders should be set at the correct angle (1 foot out at bottom for every 4 foot of ladder height) to ensure stability.

• Only ladders that are not electrically conductive (wooden ladders or ladders with fiberglass rails) shall be used to perform electrical service work.

• Stationary ladders with a height greater than six (6) feet shall be caged or fall protection such as an inertia reel, static line with cable-grabbing device or double lanyard climbing method shall be used.

4.8.7 Tank Roofs

Walking or standing on a tank roof is not permitted without fall protection. Working on a tank roof without fall protection in the form of guard rails or a full body harness system may be permitted with a Work Permit which includes proper job planning and a written HSE procedure.

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4.9 Respiratory Protection

Respiratory protection shall be worn when working in areas where

respiratory hazards exist and are not controllable by other means. Some respiratory hazards which may be encountered include hydrogen sulfide (H2S), chlorine, galvanized pipe welding, sand blasting, or insulation work

where Man Made Mineral Fibers (MMMF) and asbestos may be present. The following requirements must be met by employees who will be using respiratory protection: (a) employee shall meet medical requirements for using this equipment; (b) employee shall receive training on the proper use, fit and maintenance of this equipment; (c) employee shall not have facial hair that will interfere with the seal of the face piece; (d) employee shall not wear eye glasses that interfere with the seal of the face piece; and (e) employee shall not wear contact lenses while using a respirator. 4.10 Personal Flotation Devices (PFD’s)

Personal flotation devices (PFD’s), such as life jackets or work vests, shall be worn and properly secured at all times by personnel riding in a boat, making boat/platform transfers, and working in areas above water (such as barges, bottom walkways and decks of platforms, etc.) without guard rails. Personnel riding in a helicopter over water shall wear inflatable PFD’s referred to as Mae West type life jackets. Belt pack type inflatable life jackets are not authorized for passengers on helicopter.

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5.0 TRANSPORTATION

5.1 Vehicles

SEPCo and contractor employees driving a vehicle used for company business shall have a valid driver’s license and use defensive-driving techniques at all times. Seat belts shall be worn by all vehicle occupants and all posted signs obeyed when driving on SEPCo locations. Driving while under the influence of alcohol or other drugs is prohibited.

While on SEPCo locations, vehicles shall be parked in a safe area or area designated by SEPCo. Also, when possible, vehicles should be parked so the driver can exit by driving forward. When leaving a vehicle, the driver shall put the vehicle in park, set the emergency brake, turn the engine off, and close the doors. If the engine must remain running while the vehicle

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is unoccupied, vehicle chock blocks shall be used to help prevent the vehicle from moving. Vehicles should be located outside the guy wire pattern of a drilling or workover rig. Guy wires shall be flagged and guarded against vehicle traffic. If it is necessary to bring a vehicle inside the guy wire pattern of the rig, a spotter shall be used to guide the vehicle and watch for hazards.

Personnel sleeping in vehicles on SEPCo locations - When personnel are sleeping in vehicles with the engine running, the occupant(s) shall first ensure:

• Vehicle is angled in a direction not in line with the wellhead.

• Vehicle is at least 100 feet from the well.

• Exhaust is not directed to any other occupied vehicle(s) and/or flowlines.

• At least one wheel is chocked.

• Emergency brake is set.

• At least one window is cracked open. 5.2 Boats

SEPCo and contractor employees shall follow the instructions of the boat captain on loading/unloading procedures, luggage storage, cargo, seating arrangements, and smoking restrictions. The captain has the authority to refuse passage to anyone he/she considers to be an unsafe passenger. All boat passengers shall walk (not run) on the boat’s deck, keep one hand free for support, and wear a personal flotation device (PFD) when getting on or off the boat. All boats operating for SEPCo shall meet U.S. Coast Guard regulations.

5.3 Helicopters

SEPCo and contractor employees shall follow the instructions of the dispatcher, HLO/SES and pilot at all times. A helicopter pre-flight HSE orientation shall be conducted prior to flying offshore. The helicopter shall not be approached until a signal is received from the pilot, HLO/SES or dispatcher. Always approach and disembark the helicopter from the side

for the SK-76 helicopter and from the forward left or right side for other types of helicopters. Never walk behind the aft cargo compartment and never walk under the helicopter tailboom. Watch and crouch down when under the turning rotors and remain clear of the tail rotor at all times.

Never use the emergency exit from the heliport unless it is a real

emergency. All helicopter passengers shall walk (not run) to or from the helicopter. Wear your seat belt tight around your hips during flight, wear hearing protection and the Mae West inflatable life vest.

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No hazardous material shall be carried on the helicopter unless the proper paperwork has been completed and the pilot has been notified of the material.

6.0 OFFSHORE (WATER) SAFETY

6.1 Swimming Requirements

SEPCo requires all personnel going to water locations to be able to swim or to have successfully completed an industry-accepted training for swimming or water survival. Water survival training can be taken by swimmers or non-swimmers alike. The training equips an individual with the basic skills to survive in the water for a sufficient amount of time to allow rescue. All personnel will be required to sign a roster attesting they are able to swim and that their employer has instructed them about the hazards and proper work practices specific to working offshore in the oil industry.

6.2 Personnel Entry Into Water

Entry into the water shall be permitted only when:

• A diver is to perform specified work.

• An abandon platform order is given.

If rescuing a person in the water when there are no other reasonable alternatives, the person performing the rescue should first remove shoes and excess clothing, wear a personal flotation device (PFD), and attach a lifeline. Other persons should be in place secure the lifeline.

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6.3 Boat-Platform Transfers

Personnel transferring between boats, platforms, and rigs shall wear a personal flotation device (PFD). Transfer by personnel basket and/or swing rope shall not be permitted without receiving proper training and an on-site orientation on the transfer. Personnel shall not board unlighted platforms or structures at night except when the accompanying boat is equipped to adequately illuminate the boarding operations. Refer to SEPCo Offshore Operations Procedure OPS0168A (Personnel Transfer Safety Procedures) for more details.

6.4 Loading Equipment on Barges

All personnel shall use proper PPE, including personal flotation devices (PFD’s), when loading equipment on a barge. The barge should be secured with a tugboat or double lines (if a tugboat is not available) and the ramp or barge level adjusted before attempting to load any equipment. During loading operations, ensure the load is centered on the barge for balance. All equipment on the barge should be properly secured with binders to prevent movement in case choppy waters are encountered during the move.

6.5 Fire and Abandonment Drills

Emergency drills shall be conducted on platforms once each month for each shift and on floating facilities (TLP and MODU) once each week. Records of these drills shall be maintained at the facility.

Each manned platform shall have a station posted in conspicuous places and signed by the person in charge. The station bill shall be corrected immediately whenever there is any change in location of equipment or personnel.

7.0 ENVIRONMENTAL

7.1 ISO 14001

SEPCo is ISO 14001 certified and committed to continual improvement of our environmental performance. The ISO 14001 standard is an

internationally recognized standard for environmental management. Commitment to continual improvement of environmental performance is required by the ISO 14001 standard and is included in SEPCo’s HSE

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Commitment & Policy. All SEPCo and contractor employees should be aware of the importance of conforming with the SEPCo HSE Policy; the environmental benefits of improved personal performance; and the significant environmental issues or risks called “e-aspects” and their potential interaction with the environment as related to specific work activities. There are six (6) environmental impact categories in SEPCo’s “e-aspects” including: (a) Emissions to Air; (b) Discharges to Water or Land; (c) Solid or Other Wastes; (d) Land/Sea Use or Contamination; (e) Material or Energy Use; and (f) Other Effects such as Noise, Vibration, Dust, etc. Each employee should read the SEPCo HSE Commitment & Policy and understand your roles and responsibilities in helping SEPCo achieve conformance to this policy especially as it relates to the ISO 14001 requirements.

7.2 Environmental Assessment

Prior to beginning any work activity, an environmental assessment should be completed to determine if adequate barriers are in place to prevent an environmental incident or permit violation.

The Environmental Assessment should evaluate whether:

• Activities generate any new discharges to the air, water, or land.

• Activities require any new permits.

• Activities affect any existing discharges.

• Existing discharges exceed the permit limits.

• Activities lessen the effectiveness of existing barriers to protect for an oil or chemical spill.

7.3 Spill (SPCC) Plans

All SEPCo locations have Spill Prevention, Containment, and Countermeasure (SPCC) response plans developed to comply with environmental regulations. It is your duty to report all environmental releases including oil spills, chemical spills, etc. as soon as possible to you’re supervisor or the SEPCo representative.

7.4 Waste Management

All waste materials shall be disposed of properly. SEPCo and contractor employees are responsible for taking the necessary steps to prevent pollution and minimize the generation of waste.

Waste management shall include the following:

• Proper identification of each individual waste stream.

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• Proper labeling, markings, manifesting, storage, and shipping of each waste stream.

Offshore Specific - For water locations, it is unlawful to dispose of any liquids, solids, or other material overboard. Failure to comply with this regulation can result in a substantial penalty.

7.5 Environmental Rules, Regulations, and Guidelines

All work activities, including those of contractors, shall comply with the rules, regulations, and guidelines specified in the SEPCo business unit’s Environmental Compliance Manual (ECM). Questions concerning the environmental policies should be directed to the local SEPCo representative or SEPCo HSE.

8.0 OCCUPATIONAL HEALTH

8.1 General

Occupational Health deals with identifying; evaluating (through monitoring, surveys, etc.); and controlling (through engineering, material substitutions, work practices, PPE, etc.) workplace health hazards.

SEPCo’s Occupational Health objectives are to:

• Protect personnel health.

• Provide a framework for recognizing and managing health hazards.

• Comply with regulatory requirements.

8.2 Use of Prescription and Over-the-Counter (OTC) Medications At a minimum, all contractors must comply with SEPCo’s policy on

medical conditions and the use of prescription and over-the-counter (OTC) medications, as per SEPCo’s Medical Condition and Medication

Procedure (HSE0071). 8.3 Medical Response Plan

It is the policy of SEPCo to provide its employees, contractors, and visitors with an organized and timely health care delivery system. The purpose of SEPCo's Medical Response Plan is to provide a guide for SEPCo

operations personnel in the management of initial on-site health care, medical evacuation, and continued care of the ill or injured employee or contractor.

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8.4 Hazard Communication (HAZCOM) / MSDS Program

The purpose of the HAZCOM / MSDS program is to ensure that all known potential hazards of substances used or present at the work place are communicated to all SEPCo and contractor employees. All contractors are responsible for training their employees on the OSHA Hazard Communication Standard (29 CFR 1910.1200).

Compliance with this program is achieved by:

• Labeling containers and providing information regarding hazards associated with unlabeled containers.

• Maintaining Material Safety Data Sheets (MSDS).

• Maintaining work place chemical inventory lists.

• Providing employees with information and training including measures employees should take to protect themselves from these hazards including proper work practices, PPE and emergency procedures.

Key hazards or conditions that may pose significant risk to health include the following:

8.5 Naturally Occurring Radioactive Material (NORM)

NORM is a low-level radiation source, which may be present in oil and gas formations. NORM is typically detected in scale build-up and can be found in tubulars, wellheads, flowlines, pits, vessels, and salt-water

disposal well equipment. NORM is primarily an ingestion and/or inhalation hazard. All SEPCo and contractor employees shall be trained in the hazards associated with NORM and procedures to avoid inhalation or ingestion.

8.6 Asbestos

Asbestos may be present in pipe/vessel insulation, brake pads, and in structural materials such as transit panels, floor tiles, and roofing felts. Asbestos is primarily an inhalation hazard. It is often difficult to

differentiate between asbestos and non-asbestos without laboratory equipment. There may be older facilities where asbestos still remains. Asbestos can present a hazard if not handled properly. To minimize the health risk it is important not to drill, cut, mine, remove, tear, step on, brush against, hammer on, or in any way disturb susp. Only trained personnel with proper equipment shall disturb or remove asbestos.

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8.7 Man-Made Mineral Fibers (MMMF)

Man-made mineral fibers (MMMF) may be present in heat and acoustical insulation. MMMF’s include fiberglass, mineral wool, and refractory ceramic fiber. MMMF’s are primarily an inhalation hazard.

MMMF’s can present a hazard if not handled properly. Only trained personnel with proper equipment shall disturb or remove MMMF’s. 8.8 Lead

Inorganic lead is typically found in paints and coatings. Lead is primarily an ingestion and/or inhalation hazard. Overexposure to lead can have serious short term or longer-term health effects.

Activities in which exposure to inorganic lead can occur include welding, cutting, sandblasting, and burning of painted and/or coated surfaces. Exposures above the Action Level (AL) of 30 micrograms of lead per cubic meter of air (µg/m3) averaged over an 8-hour workday triggers exposure monitoring, training, and medical surveillance requirements. The

Permissible Exposure Limit (PEL) is 50 micrograms of lead per cubic meter of air (µg/m3) averaged over an 8-hour workday.

8.9 Heat and Cold Stress

For activities in which exposure to heat and/or cold stress can occur, the need to develop work/rest cycles, provide protective clothing and

equipment, etc. shall be evaluated. 8.10 Food Control

Food/drink preparation and storage/consumption practices should prevent contamination from chemicals, oils, dirt, biological agents or any foreign matter. Facilities for washing before food preparation and consumption should be available near the workplace. Eating areas separate from work areas should be provided wherever practical.

9.0 PERMIT-TO-WORK (PTW) PROCESS

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SEPCo utilizes a Permit-to-Work (PTW) process on routine and non-routine work activities to ensure hazards and risks associated with these activities are identified and safeguarded. The PTW process is a comprehensive process for analyzing, planning, authorizing and executing work in a manner to prevent HSE incidents and is much more than simply issuing permission to conduct certain jobs.

9.2 Work Permit

One of the key tools utilized in the PTW process is the Work Permit, which is a written document that authorizes identified personnel to conduct certain work activities within designated boundary conditions such as time, place, and the specific work steps required to ensure the job is completed in a manner to prevent HSE incidents. The Work Permit will generally be issued on a daily basis and re-issued at a shift/tour change or significant change in hazard classification of job assignment. Consult the SEPCo representative for those work activities that shall require a Work Permit, as well as those activities which may require a Work Permit depending on special situations such as simultaneous operations (SIMOPS).

The Work Permit document shall contain the following at a minimum:

• When the specified work will begin (date/time) and end and/or when a new permit will be required (date/time). A formal hand-over procedure must be in place for when Work Permits are issued for periods longer than one shift/tour and/or when Work Permit authorization changes.

• Who the permit is issued to (including company and individual’s name).

• Where the specified work will take place.

• Full description of what work will be performed including proposed tasks and objectives and description of equipment to be used.

• Special considerations for safeguarding short service employees (SSE’s).

• Description of all major hazards which could be encountered during the job, as well as, documentation of appropriate controls for each hazard identified.

• PPE necessary for specified work that will take place.

• Identify specific standards/procedures/guidelines that are applicable to work that will take place.

• Jobs involving Permit-required Confined Space Entry (PRCS), Lockout/Tagout (LOTO); Excavation and Trenching; or Hot Work will generally require additional documentation.

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• Actions to be taken in the event of an HSE incident including appropriate emergency response and notification phone numbers for SEPCo and contractor.

• Reference to all other activities that may be impacted by work which will be performed (including other Work Permits) to ensure alignment and coordination.

• Signatures of all workers who have reviewed the Work Permit and agree to meet all the operational and HSE requirements.

• Final documentation and formal hand-over procedure declaring the work has been completed and the job site left with no HSE issues or problems and ready to return to service.

• Need to provide for the suitable display of Work Permits. 9.3 JSA/JHA

Another key tool to the process, besides the Work Permit, is the Job Safety/Hazard Analysis (JSA/JHA). The JSA/JHA also helps ensure appropriate precautions and procedures are employed to eliminate or minimize identified HSE hazards and risks for activities conducted. The JSA/JHA is a process for discussing and documenting each step of a job, identifying the existing or potential HSE hazards and then determining the best way to perform the job to reduce or eliminate the hazards. JSA/JHA are effective tools to be used for jobs that will take place even when a Work Permit is not required.

10.0 MANAGEMENT OF CHANGE (MOC) PROCESS

SEPCo requires that a Management of Change (MOC) process be used for all SEPCo and contractor operations in which major changes are planned, both permanent and temporary, that can have a significant impact on the HSE aspects of a job or operation. The purpose of the MOC process is to ensure hazards and risks associated with these changes are identified and managed.

Examples of “changes” may include:

• Physical changes to equipment.

• Equipment and/or structural additions to a physical asset.

• Changes to software.

• Personnel changes (staff and management).

• Changes in project scope.

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The MOC Process provides for appropriate review, approval,

implementation, and tracking. Contractors shall have an MOC process consistent with SEPCo's process. An appropriate SEPCo employee should review changes to contractor equipment, procedures, etc., to ensure proper use of the MOC process and also determine if any adverse affects to HSE could result from the change. Consult the SEPCo

representative for those changes that will require use of the MOC process.

11.0 PROCESS SAFETY MANAGEMENT (PSM)

OSHA 1910.119

Contractors will be informed if a facility is covered under OSHA Process Safety Management (29 CFR 1910.119). Site-specific hazards will be discussed with the contractor before work begins. Under this guideline the contractor is responsible to see that their employees are trained to perform their jobs safely, and have been instructed in the process hazards and emergency action plans for the facility. The contractor shall maintain documentation of employee training. Documentation shall include employee identification, training dates, and description of the training and the means used to verify the employees understanding.

The contractor shall ensure that their employees follow all safety requirements, and the safe work practices listed in SEPCo’s written operation procedures. The contractor should advise SEPCo of any unique hazards resulting from the performance of their work at a covered facility. SEPCo appreciates employee input to improve or enhance the facility safety.

12.0 GENERAL OPERATIONS

12.1 HSE in the Office

HSE in the office is as important as HSE in the field. Each office shall have an emergency evacuation plan and shall conduct an evacuation drill annually. Both SEPCo and contractor employees shall be familiar with emergency evacuation procedures, evacuation routes, and specific responsibilities. Office doors shall be closed, but left unlocked during an emergency evacuation. Elevators shall not be used. Use handrails when ascending/descending stairs. Hallways, entrances, and exits shall be kept

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free of obstructions. Material shall be stored in an orderly fashion and work areas kept clean and free of tripping hazards such as cords, drawers, books, files, etc.

12.2 Lifting of Loads by Personnel

Back injuries may result from improper lifting techniques. Lifting a load that is too heavy, or lifting in the wrong position, can cause an injury. Follow these guidelines to lift safely:

• Make sure the area is clear of tripping hazards.

• Face the load you’re about to lift.

• Bend your knees.

• Keep the load close to your body.

• Keep your back straight.

• Use your legs, not your back, to lift the load.

• Do not twist your body while carrying a heavy load.

• Do not try lifting a load that is too heavy - ask for help.

• When lifting a load with another person(s), communicate with the other person(s) before lowering your end of the load.

12.3 Lockout / Tagout

Lockout/Tagout is a procedure required by OSHA to isolate personnel from all potential energy sources when performing maintenance or service on equipment; especially when that maintenance or service requires the disabling or removal of normal guards and safety devices. Potential energy sources include electrical, mechanical, pneumatic, hydraulic, thermal, chemical and all forms of potential stored energy. Contractor

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shall have written Lockout/Tagout program in effect. A logbook of Lockout/Tagouts shall be maintained for each SEPCo location.

Lockout/Tagout Procedure:

• SEPCo and contractor employees shall share information prior to the start of the work requiring Lockout/Tagout to make each other fully aware of the other’s Lockout/Tagout procedures.

• Repairs, service or alterations shall not be made on equipment in operation. All equipment shall be shut down and a Lockout/Tagout device used in such a manner that the equipment cannot be accidentally started while being worked on. The power switch of the equipment to be worked on shall be Locked out/Tagged out.

• To ensure the equipment has been properly locked out of service prior to starting any work, a qualified person shall attempt to turn on the power source to ensure the equipment does not become energized.

• Drilling /Workover Rig Specific - Before equipment is unplugged or plugged into a power distribution panel, the power source shall be Locked out/Tagged out. This includes all equipment that is unplugged or plugged into the SCR distribution panel during rig moves.

• Examples of equipment repairs or maintenance that require Lockout/Tagout procedures include, but are not limited to, those listed below. Consult your supervisor or the SEPCo representative for site specific work requiring Lockout/Tagout procedures.

◊ Changing filters.

◊ Pump repairs or changing swabs/liners.

◊ Repairs to paddles in tanks or cleaning of tanks with paddles.

◊ Maintenance on the rig draw works such as adjusting the brakes, greasing, inspections, etc.

◊ Generator repairs.

◊ Compressor repairs. 12.4 Confined Space Entry

Confined space entry is defined as entry of personnel into a confined space such as a tank, vessel, rig cellar, earth pit, etc. A confined space is defined as space that: (a) has an open top and is more than four (4) feet in depth; (b) has openings large enough and configured so that a person can physically enter the space and perform work; (c) has limited or restricted means of entry or exit; and (d) is not designed for continuous human occupancy.

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Confined Space Entry Requiring a Work Permit - Entry in a confined space can expose personnel to one or more of the following hazards, in which case a Work Permit shall be required per OSHA 29 CFR 1910.146 for personnel to enter space:

• Hazardous atmosphere such as toxic or flammable vapors.

• Oxygen-deficient atmosphere.

• Material, such as mud or sludge, that has the potential for engulfing an entrant.

• An internal configuration such that the entrant could be trapped or asphyxiated.

• Inwardly converging walls or floors, which slope downward and tapers to a small cross section.

• Other recognized serious health or safety hazards.

Under no circumstances shall an employee be allowed to enter a confined space without a properly completed Work Permit approved by the

contractor and SEPCo supervisor. The Work Permit shall have a Sign-In/Sign-Out sheet for entrants and the hazards shall be discussed with the entrant prior to that person entering the space.

All confined spaces that can be readily accessed and have the potential to contain hazards shall be barricaded or labeled “DANGER DO NOT

ENTER - ENTRY PROCEDURES REQUIRED”. Minimum requirements for entering confined spaces:

• The air in a confined space shall be tested prior to a person entering the space for oxygen (O2) content; Lower Explosive Limit

(LEL); and hydrogen sulfide (H2S) in that order with an approved and

calibrated device by a person trained and certified to use the device. DANGER levels are as follows :

◊ Oxygen (O2) content below 19.5% or above 23.5%.

◊ Lower Explosive Limit (LEL)10% of LEL.

◊ Hydrogen sulfide (H2S) - 10 parts per million (ppm).

• If the air in a confined space is contaminated, the space shall be purged until an acceptable working atmosphere is achieved prior to a person entering the space.

• When a person is in a confined space, ventilation into the space shall be provided at a rate of 3 air volume changes per hour. Mechanical ventilation via blowers, etc. shall be required if natural ventilation is not sufficient. Drilling/Workover Rig Specific Mechanical ventilation via bug blowers, etc. shall be required for mud tanks prior to entering and during the cleaning operation.